Liberty India v. CIT

317 ITR 218Supreme Court of India2009#109 most cited

What is Liberty India v. CIT authority for?

The Supreme Court clarified that for profits and gains to be eligible for deductions under sections like 10B, 80IA, or 80IB, the income must be "derived from" or have a direct nexus to the eligible business activity. Income from incidental sources like the sale of scrips/licenses or interest on employee loans is generally not considered as derived from the eligible business for such deductions.

571

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2009 to 2026.

Also referred to as

Liberty India v. CIT · 317 ITR 218 · section 10B · section 80IA · section 80IB · profits derived from · direct nexus · eligible business · export undertaking deduction · sale of scrips income · interest income deduction

Also reported as

183 Taxmann 349

Sections most often in play

Section 143(3)Section 14ASection 10BSection 80IBSection 147Section 80IASection 1961Section 250
Read the full judgment

Issues it is cited on

section 75section 80hsection 80hhsection 80hhcsection 80icsection 80ibeligible businessdeduction under section 80iasection 80isection 80iadisallowance u/s 14agross total income

Judgments citing Liberty India v. CIT

Maharashtra Airport Development Company Ltd., Mumbai vs. ACIT-3(2)(1), Mumbai

ITA 521/MUM/2019[2088-09]Status: DisposedITAT Mumbai15 Mar 2024AY 2088-09

Bench: Shri Kuldip Singh & Ms. Padmavathy Sassessment Year: 2008-09 Assessment Year: 2012-13 Assessment Year: 2015-16 M/S. Maharashtra Airport Deputy Commissioner Of Development Company Income Tax, Ltd., Circle (3)(2)(1), 6Th Floor, Room No.608, 6Th Floor, Vs. World Trade Centre, Aayakar Bhawan, Tower No.1, Cuffe Parade, M.K. Road, Mumbai – 400 005 Mumbai - 400020 Pan: Aadcm9623M (Appellant) (Respondent) Assessment Year: 2008-09 Assessment Year: 2012-13 Assessment Year: 2013-14 Assessment Year: 2014-15 Assessment Year: 2015-16 Dy/Asst. Commissioner Of M/S. Maharashtra Airport Income Tax-(3)(2)(1), Development Co. Ltd., Vs. 12Th Floor, Room No.608/674, 6Th Floor, World Trade Centre, Aayakar Bhavan, Tower No.1, Cuffe Parade

For Appellant: Shri Rushabh Mehta, A.RFor Respondent: Smt Sanyogita Nagpal, D.R
Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “D”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER AND MS. PADMAVATHY S, ACCOUNTANT MEMBER Assessment Year: 2008-09 Assessment Year: 2012-13 Assessment Year: 2015-16 M/s. Maharashtra Airport Deputy Commissioner of Development Company Income Tax, Ltd., Circle (3)(2)(1), 6th Floor, Room No.608, 6th Floor, Vs. World Trade Centre, Aayakar Bhawan, Tower No.1, Cuffe Parade, M.K. Road, Mumbai – 400 005 Mumbai - 400020 PAN: AADCM9623M (Appellant) (Respondent) Assessment Year: 2008-09 Assessment Year: 2012-13 Assessment Year: 2013-14 Assessment Year: 2014-15 Assessmen…

ACIT-3(2)(1), Mumbai vs. Maharashtra Airport Development Company Ltd., Mumbai

ITA 7498/MUM/2018[2008-09]Status: DisposedITAT Mumbai15 Mar 2024AY 2008-09

Bench: Shri Kuldip Singh & Ms. Padmavathy S

Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “D”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER AND MS. PADMAVATHY S, ACCOUNTANT MEMBER ITA No.521/M/2019 Assessment Year: 2008-09 ITA No.3682/M/2017 Assessment Year: 2012-13 ITA No.522/M/2019 Assessment Year: 2015-16 M/s. Maharashtra Airport Development Company Ltd., 6th Floor, World Trade Centre, Tower No.1, Cuffe Parade, Mumbai - 400 005 Deputy Commissioner of Income Tax, Circle (3)(2)(1), Vs. Room No.608, 6th Floor, Aayakar Bhawan, M.K. Road, Mumbai - 400020 PAN: AADCM9623M (Appellant) (Respondent) ITA No.7498/M/2018 Assessment Year: 2008-09 ITA No.…

DCIT 3(2)(1), Mumbai vs. Maharashtra Airport Developement Co. Ltd, Mumbai

ITA 7258/MUM/2017[2013-14]Status: DisposedITAT Mumbai15 Mar 2024AY 2013-14

Bench: Shri Kuldip Singh & Ms. Padmavathy S

Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “D”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER AND MS. PADMAVATHY S, ACCOUNTANT MEMBER ITA No.521/M/2019 Assessment Year: 2008-09 ITA No.3682/M/2017 Assessment Year: 2012-13 ITA No.522/M/2019 Assessment Year: 2015-16 M/s. Maharashtra Airport Development Company Ltd., 6th Floor, World Trade Centre, Tower No.1, Cuffe Parade, Mumbai - 400 005 PAN: AADCM9623M (Appellant) Deputy Commissioner of Income Tax, Circle (3)(2)(1), Vs. Room No.608, 6th Floor, Aayakar Bhawan, M.K. Road, Mumbai - 400020 (Respondent) ITA No.7498/M/2018 Assessment Year: 2008-09 ITA No.…

DCIT 3(2)(1), Mumbai vs. Maharashtra Airport Developement Co. Ltd, Mumbai

ITA 3704/MUM/2017[2012-13]Status: DisposedITAT Mumbai15 Mar 2024AY 2012-13

Bench: Shri Kuldip Singh & Ms. Padmavathy Sassessment Year: 2008-09 Assessment Year: 2012-13 Assessment Year: 2015-16 M/S. Maharashtra Airport Deputy Commissioner Of Development Company Income Tax, Ltd., Circle (3)(2)(1), 6Th Floor, Room No.608, 6Th Floor, Vs. World Trade Centre, Aayakar Bhawan, Tower No.1, Cuffe Parade, M.K. Road, Mumbai – 400 005 Mumbai - 400020 Pan: Aadcm9623M (Appellant) (Respondent) Assessment Year: 2008-09 Assessment Year: 2012-13 Assessment Year: 2013-14 Assessment Year: 2014-15 Assessment Year: 2015-16 Dy/Asst. Commissioner Of M/S. Maharashtra Airport Income Tax-(3)(2)(1), Development Co. Ltd., Vs. 12Th Floor, Room No.608/674, 6Th Floor, World Trade Centre, Aayakar Bhavan, Tower No.1, Cuffe Parade

For Appellant: Shri Rushabh Mehta, A.RFor Respondent: Smt Sanyogita Nagpal, D.R
Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “D”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER AND MS. PADMAVATHY S, ACCOUNTANT MEMBER Assessment Year: 2008-09 Assessment Year: 2012-13 Assessment Year: 2015-16 M/s. Maharashtra Airport Deputy Commissioner of Development Company Income Tax, Ltd., Circle (3)(2)(1), 6th Floor, Room No.608, 6th Floor, Vs. World Trade Centre, Aayakar Bhawan, Tower No.1, Cuffe Parade, M.K. Road, Mumbai – 400 005 Mumbai - 400020 PAN: AADCM9623M (Appellant) (Respondent) Assessment Year: 2008-09 Assessment Year: 2012-13 Assessment Year: 2013-14 Assessment Year: 2014-15 Assessmen…

Maharashtra Airport Development Company Ltd, Mumbai vs. DCIT Cir 3(2)(1), Mumbai

ITA 3682/MUM/2017[2012-13]Status: DisposedITAT Mumbai15 Mar 2024AY 2012-13

Bench: Shri Kuldip Singh & Ms. Padmavathy S

Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “D”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER AND MS. PADMAVATHY S, ACCOUNTANT MEMBER ITA No.521/M/2019 Assessment Year: 2008-09 ITA No.3682/M/2017 Assessment Year: 2012-13 ITA No.522/M/2019 Assessment Year: 2015-16 M/s. Maharashtra Airport Development Company Ltd., 6th Floor, World Trade Centre, Tower No.1, Cuffe Parade, Mumbai - 400 005 PAN: AADCM9623M (Appellant) Deputy Commissioner of Income Tax, Circle (3)(2)(1), Vs. Room No.608, 6th Floor, Aayakar Bhawan, M.K. Road, Mumbai - 400020 (Respondent) ITA No.7498/M/2018 Assessment Year: 2008-09 ITA No.…

M/S.Va Tech Wabag Ltd, Chennai vs. ACIT Central Circle 3(2), Chennai

The appeal stand allowed in terms of our above order

ITA 503/CHNY/2023[2006-07]Status: DisposedITAT Chennai13 Mar 2024AY 2006-07

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manomohan Das

For Appellant: Shri R. Vijayaraghavan (Advocate)-Ld. ARFor Respondent: Shri P. Sajit Kumar (JCIT) – Ld. Sr. DR
Section 143(3)Section 147Section 41(1)Section 80ISection 80l

…had discharged the onus by furnishing all the material facts necessary for the assessment fully and truly. Accordingly, reopening was held to be valid in law. The claim on merit was also rejected, inter-alia, in terms of decision in Liberty India Ltd vs CIT (317 ITR 218). Aggrieved, the assessee is in further appeal before us. Our findings and Adjudication 7. The basic facts as well as relevant dates as enumerated in preceding paragraphs are not in dispute. It emerges that in original assessment order dated 26-12-2008, Ld. AO denied impugned deduction as claimed by the assessee u/s 80IA for Rs.14.28 Crores. Howe…

ACIT(E), Circle-2, Ahmedabad vs. Vadodara Urban Development Authority, Vadodara

In the result, the appeal filed by the Revenue in ITA No

ITA 389/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad28 Feb 2024AY 2013-14

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 12ASection 22Section 271(1)(c)

…decided that the penalty con't be levied under section 271(1) (C) only because the deduction claimed has not been allowed viz: a. Reliance Petro Products Pvt. Ltd. (2010)230 CTR 320 (SC) b. M/s Aakar Associates ITA No. 3516/Ahd/2010 c. Liberty India Vs CIT 317 ITR 218 d. CIT Vs Sterling Foods India (1999) 237 ITR 579 e. CIT Vs Budh Well Co Operative Sugar Mills P&H HC f. CIT Vs Harshvardhan - Rajasthan High Court g. CIT Vs Raj Overseas (2011) 336 ITR 261 (P&H) h. CIT Vs Lakhani India Ltd. (2010) 324 ITR 73 (P&H) 7.1. The assessee also submitted the penalty proceedings are separate from assessment proceedings…

ACIT(E), Circle-2, Ahmedabad vs. Vadodara Urban Development Authority, Vadodara

In the result, the appeal filed by the Revenue in ITA No

ITA 388/AHD/2023[2009-10]Status: DisposedITAT Ahmedabad28 Feb 2024AY 2009-10

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 12ASection 22Section 271(1)(c)

…decided that the penalty con't be levied under section 271(1) (C) only because the deduction claimed has not been allowed viz: a. Reliance Petro Products Pvt. Ltd. (2010)230 CTR 320 (SC) b. M/s Aakar Associates ITA No. 3516/Ahd/2010 c. Liberty India Vs CIT 317 ITR 218 d. CIT Vs Sterling Foods India (1999) 237 ITR 579 e. CIT Vs Budh Well Co Operative Sugar Mills P&H HC f. CIT Vs Harshvardhan - Rajasthan High Court g. CIT Vs Raj Overseas (2011) 336 ITR 261 (P&H) h. CIT Vs Lakhani India Ltd. (2010) 324 ITR 73 (P&H) 7.1. The assessee also submitted the penalty proceedings are separate from assessment proceedings…

ACIT(E), Circle-2, Ahmedabad vs. Vadodara Urban Development Authority, Vadodara

In the result, the appeal filed by the Revenue in ITA No

ITA 386/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad28 Feb 2024AY 2014-15

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 12ASection 22Section 271(1)(c)

…decided that the penalty con't be levied under section 271(1) (C) only because the deduction claimed has not been allowed viz: a. Reliance Petro Products Pvt. Ltd. (2010)230 CTR 320 (SC) b. M/s Aakar Associates ITA No. 3516/Ahd/2010 c. Liberty India Vs CIT 317 ITR 218 d. CIT Vs Sterling Foods India (1999) 237 ITR 579 e. CIT Vs Budh Well Co Operative Sugar Mills P&H HC f. CIT Vs Harshvardhan - Rajasthan High Court g. CIT Vs Raj Overseas (2011) 336 ITR 261 (P&H) h. CIT Vs Lakhani India Ltd. (2010) 324 ITR 73 (P&H) 7.1. The assessee also submitted the penalty proceedings are separate from assessment proceedings…

The ACIT(E), Circle-2, Ahmedabad vs. Vadodara Urban Development Authority, Vadodara

In the result, the appeal filed by the Revenue in ITA No

ITA 379/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad28 Feb 2024AY 2011-12

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 12ASection 22Section 271(1)(c)

…decided that the penalty con't be levied under section 271(1) (C) only because the deduction claimed has not been allowed viz: a. Reliance Petro Products Pvt. Ltd. (2010)230 CTR 320 (SC) b. M/s Aakar Associates ITA No. 3516/Ahd/2010 c. Liberty India Vs CIT 317 ITR 218 d. CIT Vs Sterling Foods India (1999) 237 ITR 579 e. CIT Vs Budh Well Co Operative Sugar Mills P&H HC f. CIT Vs Harshvardhan - Rajasthan High Court g. CIT Vs Raj Overseas (2011) 336 ITR 261 (P&H) h. CIT Vs Lakhani India Ltd. (2010) 324 ITR 73 (P&H) 7.1. The assessee also submitted the penalty proceedings are separate from assessment proceedings…

Addl CIT 8(1), Mumbai vs. M/S. Sanofi India Limited (Formerly Known As M/S. Aventis Pharma Ltd), Mumbai

In the result, the C.O. of the assessee for AY 2007-08 is partly allowed

ITA 6698/MUM/2011[2007-08]Status: DisposedITAT Mumbai23 Feb 2024AY 2007-08

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Respondent: Shri Ajay Chandra (CIT-DR) &
Section 32Section 32(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI VIKAS AWASTHY, JM & MS PADMAVATHY S, AM I.T.A. No. 6626/Mum/2009 (Assessment Year: 2005-06) Sanofi India Limited The Addl. CIT, Range-8(1), (Formerly known as Aventis Pharma Aayakar Bhavan, Ltd.), Sanofi House, CTS 117-B, M.K. Road, Mumbai-400020. Vs. L&T Business Park, Saki Vihar Road Powai, Mumbai- 400072 PAN : AAACH2736F Appellant) : Respondent) I.T.A. No. 7987/Mum/2010 (Assessment Year: 2006-07) Sanofi India Limited The Addl. CIT, Range-8(1), (Formerly known as Aventis Pharma 2nd Floor, Aayakar Bhavan, Ltd.), Sanofi House, CTS 117-B, M.K. Road…

Addl CIT RG 8(1), Mumbai vs. M/S. Sanofi India Limited (Formerly Known As M/S. Aventis Pharma Ltd), Mumbai

In the result, the C.O. of the assessee for AY 2007-08 is partly allowed

ITA 7712/MUM/2010[2006-07]Status: DisposedITAT Mumbai23 Feb 2024AY 2006-07

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Respondent: Shri Ajay Chandra (CIT-DR) &
Section 32Section 32(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI VIKAS AWASTHY, JM & MS PADMAVATHY S, AM I.T.A. No. 6626/Mum/2009 (Assessment Year: 2005-06) Sanofi India Limited The Addl. CIT, Range-8(1), (Formerly known as Aventis Pharma Aayakar Bhavan, Ltd.), Sanofi House, CTS 117-B, M.K. Road, Mumbai-400020. Vs. L&T Business Park, Saki Vihar Road Powai, Mumbai- 400072 PAN : AAACH2736F Appellant) : Respondent) I.T.A. No. 7987/Mum/2010 (Assessment Year: 2006-07) Sanofi India Limited The Addl. CIT, Range-8(1), (Formerly known as Aventis Pharma 2nd Floor, Aayakar Bhavan, Ltd.), Sanofi House, CTS 117-B, M.K. Road…

Sanofi India Ltd Formerly Known As Aventis Pharma Ltd, Mumbai vs. Addl CIT RG 8(1), Mumbai

In the result, the C.O. of the assessee for AY 2007-08 is partly allowed

ITA 6626/MUM/2009[2005-06]Status: DisposedITAT Mumbai23 Feb 2024AY 2005-06

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Respondent: Shri Ajay Chandra (CIT-DR) &
Section 32Section 32(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI VIKAS AWASTHY, JM & MS PADMAVATHY S, AM I.T.A. No. 6626/Mum/2009 (Assessment Year: 2005-06) Sanofi India Limited The Addl. CIT, Range-8(1), (Formerly known as Aventis Pharma Aayakar Bhavan, Ltd.), Sanofi House, CTS 117-B, M.K. Road, Mumbai-400020. Vs. L&T Business Park, Saki Vihar Road Powai, Mumbai- 400072 PAN : AAACH2736F Appellant) : Respondent) I.T.A. No. 7987/Mum/2010 (Assessment Year: 2006-07) Sanofi India Limited The Addl. CIT, Range-8(1), (Formerly known as Aventis Pharma 2nd Floor, Aayakar Bhavan, Ltd.), Sanofi House, CTS 117-B, M.K. Road…

Reliance Corporation, Mumbai vs. Dy. CIT Central Circle - 1, Thane

In the result, all the three appeals of the assessee are allowed

ITA 2725/MUM/2023[2013-14]Status: DisposedITAT Mumbai20 Feb 2024AY 2013-14

Bench: Shri B.R. Baskaran (Am) & Shri Sandeep Singh Karhail (Jm)

Section 147Section 68

…as under:- …………. (ii) Further it was a submission on behalf of the Revenue that such large amount of share premium gives rise to suspicion on the genuineness (identity) of the shareholders i.e. they are bogus. The Apex Court in CIT v/s. Lovely Exports (P)Ltd. 317 ITR 218 in the context to the preamended Section 68 of the Act has held that where the Revenue urges that the amount of share application money has been received from bogus shareholders then it is for the Income Tax Officer to proceed by reopening the assessment of such shareholders and assessing them to tax in accordance with law. It does not entitle th…

Reliance Corporation, Mumbai vs. Dy. CIT Central Circle - 1, Thane

In the result, all the three appeals of the assessee are allowed

ITA 2724/MUM/2023[2011-12]Status: DisposedITAT Mumbai20 Feb 2024AY 2011-12

Bench: Shri B.R. Baskaran (Am) & Shri Sandeep Singh Karhail (Jm)

Section 147Section 68

…as under:- …………. (ii) Further it was a submission on behalf of the Revenue that such large amount of share premium gives rise to suspicion on the genuineness (identity) of the shareholders i.e. they are bogus. The Apex Court in CIT v/s. Lovely Exports (P)Ltd. 317 ITR 218 in the context to the preamended Section 68 of the Act has held that where the Revenue urges that the amount of share application money has been received from bogus shareholders then it is for the Income Tax Officer to proceed by reopening the assessment of such shareholders and assessing them to tax in accordance with law. It does not entitle th…

Reliance Corporation, Mumbai vs. Dy. CIT, Central Circle - 1, Thane

ITA 2723/MUM/2023[2014-15]Status: DisposedITAT Mumbai20 Feb 2024AY 2014-15

Bench: Shri B.R. Baskaran (Am) & Shri Sandeep Singh Karhail (Jm)

Section 147Section 68

…s held as under:- (ii) Further it was a submission on behalf of the Revenue that such large amount of share premium gives rise to suspicion on the genuniness (identity) of the shareholders i.e. they are bogus. The Apex Court in CIT v/s. Lovely Exports (P)Ltd. 317 ITR 218 in the context to the preamended Section 68 of the Act has held that where the Revenue urges that the amount of share application money has been received from bogus shareholders then it is for the Income Tax Officer to proceed by reopening the assessment of such shareholders and assessing them to tax in accordance with law. It does not entitle th…

M/S Jr Fiber Glass Industries Pvt Ltd, Mumbai vs. National Faceless Appeal Centre, Mumbai

The appeal is allowed

ITA 2848/MUM/2023[2008-2009]Status: DisposedITAT Mumbai31 Jan 2024AY 2008-2009

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.2848/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2009-10) M/S. Jr Fiber Glass Industries Pvt. Ltd.

For Appellant: Shri Satyaprakash SinghFor Respondent: Ms. Kavitha Kaushik (Sr. AR)
Section 133(6)Section 147Section 68

…found satisfied. (ii) Further it was a submission on behalf of the Revenue that such large amount of share premium gives rise to suspicion on the genuiiness (identity) of the shareholders i.e. they are bogus. The Apex Court in CIT vis. Lovely Exports (P) Ltd. 317 ITR 218 in the context to the pre-amended Section 68 of the Act has held that where the Revenue urges that the amount of share application money has been received from bogus shareholders then it is for the Income Tax Officer to proceed by reopening the assessment of such shareholders and assessing them to tax in accordance with law. It does not entitle t…

Nhdc Limited, Bhopal vs. DCIT - 3(1), Bhopal

In the result, the appeal of the revenue is dismissed, Cross appeal of the assesse is partly allowed for statistical purposes and CO is dismissed being infructuous

ITA 40/IND/2021[2015-16]Status: DisposedITAT Indore11 Dec 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaninhdc Limited Dcit, 3(1) F-01, Nhdc Parisar, Shyamla Bhopal Vs. Hills Bhopal -462013 (Appellant / Assessee) (Revenue) Pan: Aabcn 1732G Dcit, 3(1) Nhdc Limited Bhopal F-01, Nhdc Parisar, Vs. Shyamla Hills Bhopal -462013 (Appellant / Revenue) (Assessee) Pan: Aabcn 1732G

Section 143(3)Section 80I

…आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI VIJAY PAL RAO, JUDICIAL MEMBER AND SHRI B.M. BIYANI, ACCOUNTANT MEMBER NHDC Limited DCIT, 3(1) F-01, NHDC Parisar, Shyamla Bhopal Vs. Hills Bhopal -462013 (Appellant / Assessee) (Revenue) PAN: AABCN 1732G DCIT, 3(1) NHDC Limited Bhopal F-01, NHDC Parisar, Vs. Shyamla Hills Bhopal -462013 (Appellant / Revenue) (Assessee) PAN: AABCN 1732G CO No.03/Ind/2021 (Arising out of ITA No.40/Ind/2021) (Assessment Years:2015-16) NHDC Limited DCIT, 3(1) F-01, NHDC Parisar, Shyamla Bhopal Hills Vs. Bhopal -462013 (App…

DCIT 3 (1), Bhopal vs. M/S Nhdc Ltd, Bhopal

In the result, the appeal of the revenue is dismissed, Cross appeal of the assesse is partly allowed for statistical purposes and CO is dismissed being infructuous

ITA 316/IND/2020[2015-16]Status: DisposedITAT Indore11 Dec 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaninhdc Limited Dcit, 3(1) F-01, Nhdc Parisar, Shyamla Bhopal Vs. Hills Bhopal -462013 (Appellant / Assessee) (Revenue) Pan: Aabcn 1732G Dcit, 3(1) Nhdc Limited Bhopal F-01, Nhdc Parisar, Vs. Shyamla Hills Bhopal -462013 (Appellant / Revenue) (Assessee) Pan: Aabcn 1732G

Section 143(3)Section 80I

…आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI VIJAY PAL RAO, JUDICIAL MEMBER AND SHRI B.M. BIYANI, ACCOUNTANT MEMBER NHDC Limited DCIT, 3(1) F-01, NHDC Parisar, Shyamla Bhopal Vs. Hills Bhopal -462013 (Appellant / Assessee) (Revenue) PAN: AABCN 1732G DCIT, 3(1) NHDC Limited Bhopal F-01, NHDC Parisar, Vs. Shyamla Hills Bhopal -462013 (Appellant / Revenue) (Assessee) PAN: AABCN 1732G CO No.03/Ind/2021 (Arising out of ITA No.40/Ind/2021) (Assessment Years:2015-16) NHDC Limited DCIT, 3(1) F-01, NHDC Parisar, Shyamla Bhopal Hills Vs. Bhopal -462013 (App…

Svp Industries Ltd., New Delhi vs. ACIT, Circle- 22(2), New Delhi

In the result, the appeals of the assessee are partly allowed in the manner as indicated above

ITA 4026/DEL/2019[2013-14]Status: DisposedITAT Delhi13 Oct 2023AY 2013-14

Bench: Shri Chandra Mohan Garg & M.Balaganesh

For Appellant: Shri M.P Rastogi, AdvFor Respondent: Shri Vipul Kashyap, Sr. DR
Section 14ASection 80ASection 80J

…wherein the Hon'ble Supreme Court held that there must be a direct nexus between the profits and gains and the industrial undertaking. 5. The ld. counsel placing reliance on the preposition rendered Hon’ble Apex Court in the case of Liberty India reported in 317 ITR 218 at page 233 (SC), contended that the Hon'ble Supreme Court held that such profits are to be computed as if such eligible business is only source of income. Therefore, the devices adopted to reduce or inflate the profits of the eligible business have to be rejected. The ld. counsel thus submitted that the ld. CIT(A) while allocating the expenses b…